Public ingredient disclosure and screening against the Red List through the Declare program offers an efficient, scalable approach to capturing a snapshot of product content and communicating it to the market. However, without better research and data, list-based screening approaches to material health are not the end-game solution to ensure the safest products.
Existing research and data is not sufficient to know all potential hazards associated with all chemicals in commerce, therefore it is impossible for authoritative hazard lists to capture all problematic chemicals. This presents the danger of regrettable substitutions, in which a chemical with known hazards (i.e. one on the Red List) is replaced with an alternative that doesn’t turn up on pertinent hazard lists, but with further research, ultimately turns out to have similar, or worse impacts. One well-known example of a regrettable substitute is bisphenol S (BPS), which quickly replaced bisphenol A (BPA) in many plastic bottles and food containers, both designed to make plastic hard and clear. Scientific studies now suggest that BPS behaves similarly to BPA in the human body, so the replacement does not necessarily make the product safer. To avoid these situations and promote informed selection of materials, a deeper approach to exploring material health through full chemical assessment of ingredients with unknown hazards is advisable.
The Transparent Material Health Imperative in LPC therefore goes beyond Declare to require full assessment(s) of all of the chemicals identified through the Declare process, where the hazards are not fully established. The Imperative requires elimination of all ingredients identified as carcinogenic, mutagenic, or reprotoxic (CMR), or persistent, bioaccumulative, toxic (PBT) substances, that present a risk of exposure to workers in the final manufacturing facility, the product installer, and/or the end user, and any reasonable end of life scenarios. These results are made transparent so that the program can be publicly evaluated and questioned, encouraging conversation and improvement.
